Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 1 UNITED STATES OF AMERICA DEPARTMENT OF TRANSPORTATION FEDERAL AVIATION ADMINISTRATION DOCKET MANAGEMENT SYSTEM 1200 NEWJERSEY AVE., SE WASHINGTON, DC 20590 **IN THE M AT** **TER OF THE PETITION FOR EXEMPTION OF:** 

## Ke**ystone Consultants, Inc.**
**FOR A N EXEMPTION SEEKING RELIEF FROM**  **THE REQUIREMENTS OF THE FAA**  **REFORM A CT AND**  **PA RT 11 OF THE FEDER**  **AL A**  **VIA TION REGULA** 

**TI ONS FROM**  **TI TLE 14 OF THE CODE OF FEDERA** **L REGUL AT**  **IONS SECTIONS**  **C.F.R. §§ 61.113 (a) & (b); 91.7(a); 91.119 (c); 91.121; 91.151(a);**

**91.405 (a); 91.407(a) (1); 91.409 (a) (2); 91.417 (a) & (b). CONCERNING COMMERCIA** **L OPERA TION OF UNM** **AN NED**  **AIR CRA** **FT SYSTEMS PURSUA** **NT TO SECTION 333 OF THE F** **AA M ODERNIZ** **AT ION**  **AN D REFORM A** **CT OF 2012 (PUBLIC L AW** **112 -** **95)**

Submitted	on February	24, 2016 Keystone	Consultants,	Inc. 32	East	Main	Street Carnegie,	PA	15106 mflaus@keystoneconsultants.net

Keycon	Inc’s Consultant Gowdy	Brothers	Aerospace,	LLC 8170	Old Carriage	Court	N.	Suite	#200 Shakopee,	MN	55379 www.GowdyBrothersAerospace.com Info@GowdyBrothers.co mGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 2 

### Table of Contents **GLOSSARY	OF	ABBREVIATIONS ................................** **................................ ...........................**  **3 INTRODUCTION	AND	INTERESTS	OF	THE	PETITIONER**  **................................ ..............**  **4 Executive	Summary**  **................................ ................................** **................................ .................**  **4 Expeditious	Summary	Grant	Approval	Request**  **................................ ................................** **...... 4**  Description	of	Type,	Make	and	Models	of	sUAV/UAS	Requested:
................................ ............. 5 Commercial	(Mission,	Operation)	Purpose:
................................ ................................ ........................ 8 Regulations	from which	the	Exemption	Relief	is	requested:
................................ ....................... 8 The	name	and	address	of	the	Petitioner:
................................ ................................ ............................. 9 **Background ................................** **................................ ................................** **................................ ...........**  **9** Commitment	to	Safety
................................ ................................ ................................ ................................ .. 9 Expertise	&	Experience................................ ................................ ................................ ............................. 10 **The	Exemption	Request ................................** **................................ ................................** **...... 11**  **Operator	Requirements ................................** **................................ ................................** **................ 13**  **Aircraft	and	Equivalent	Level	of	Safety ................................** **................................ ....................**  **16 Specific	Uses	Public	Benefits**  **................................ ................................** **................................ .......**  **20 Equivalent	Level	of	Safety** **................................ ................................** **................................ .............**  **21** 14	C.F.R.	§	91.7(a):	Civil	aircraft	airworthiness.
................................ ................................ ............. 22 14	C.F.R.	§91.119:	Minimum	safe	altitudes
................................ ................................ ...................... 22 14	C.F.R.	§91.121	Altimeter	Settings
................................ ................................ ................................ ... 23 14	C.F.R.	§	91.151(a):	Fuel	Requirements	for	Flight	in	VFR	Conditions
.............................. 23 14	C.F.R.	§91.405	(a);	91 .407	(a)	(1);	91.409(a)	(2);	91.417(a)	&	(b):	Maintenance Inspections ................................ ................................ ................................ ................................ ..................... 24 **Federal	Register	Publication ................................** **................................ .............................**  **25 Privacy	and	National	Security**  **................................ ................................** **........................... 25**  **Summary ................................** **................................ ................................** **................................ ...**  **25 APPENDIX	A**  **- EXEMPTION	PATTERN**  **................................ ................................** **....................... 28**  **APPENDIX	B -**  **TECHNICAL	MANUALS	AN D	SPECIFICATIONS** **................................ ............**  **29 APPENDIX	C**  **- COMMERCIAL	(MISSION/OPERATION)	P** **URPOSE -**  **FAA	PREVIOUS APPROVED	EXEMPTION	NUMBERS**  **................................ ................................** **........................... 30**  **APPENDIX	D -**  **EQUIPMENT -**  **FAA	PREVIOUS	APPROVED	EXEMPTION	NUMBERS ....**  **31 APPENDIX	E**  **- EXEMPTION	14	C.F.R**  **- FAA	PREVIOUS	APPROVED	EXEMPTION**  **NUMBERS ................................** **................................ ................................** **................................ ............**  **32 APPENDIX	F**  **- MONTHLY	MAINTENANCE**  **AN D	REPAIR	LOG**  **................................ .............**  **33 APPENDIX	G**  **– MOTION	PICTURE	AND	TELEVISION	FLIGHT	OPERATIONS	MANUAL**  **VERSION	1.0 ................................** **................................ ................................** **................................ .......**  **34**Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 3 

## GL**OSSARY OF ABBREVIA TIONS** 

AGL Above	Ground	Level AOI Area	of	Interest ATC Air	Traffic	Control ATO Air	Traffic	Organization AV Aerial	Vehicle CFR Code	of	Federal	Regulations COA Certificate	of Authorization FAA Federal	Aviation	Administration FAR Federal	Aviation	Regulation GCS Ground	Control	Station GPS Global	Positioning	System LOL Loss	of	Link NAS National	Airspace	System NOTAM Notice	To	Airman PIC Pilot	In	Command Section	333 FAA	Modernization	and	Reform	Act	of	2012	(FMRA)	Section	333 SO Safety	Observer SOP Standard	Operating	Procedures sUAS Small	Unmanned	Aircraft	System sUAV Small	Unmanned	Aircraft	Vehicle UA Unmanned	Aircraft UAS Unmanned	Aircraft	System UAV Unmanned	Aircraft	Vehicle VFR Visual	Flight	Rules VLOS Visual	Line	of	Site VMC Visual	Meteorological	Conditions VTOL Vertical	Take- Off	and	LandingGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 4 

## INTRODUCTION AND INTERESTS OF THE PETITIONER Dear	Sir	or	Madam: Pursuant to Section 333 of the FAA Modernization and Reform Act of 2012 (the “Reform Act”) and 14 C.F.R. Part 11, Keystone Consultants, Inc., (“Keycon Inc”) Operator of Small Unmanned Aircraft Systems (“sUAS’s”) equipped to offer ondemand commercial UAS operations for a host of industries and applications and to perform the purposes listed below, hereby applies for an exemption from the listed Federal Aviation Regulations (“FARs”) to allow commercial operation of its sUAVs/UAS, so long as such operations are conducted within and under the conditions outlined herein or as may be established by the FAA in an exemption granted	under	either	Section	333	or Section	49	U.S.C.	§44701(f) As described more fully below, the requested exemption would permit the operation of a UAS under controlled conditions in airspace that is 1) limited; 2) predetermined; and 3) would provide safety enhancements in the fields in which it will operate, which now depend upon conventional aircraft or humans climbing high on dangerous structures, walking in insect laden swamps, and working adjacent to treacherous infrastructure. Approval of this exemption would thereby enhance safety and fulfill the Secretary of Transportation’s (the FAA Administrator’s) responsibilities	to	“... establish requirements	for	the	safe	operation of such aircraft systems in the national airspace system.” Section 333(c) of the Reform	Act. 1 

## Ex**ecutive Summary**  **Expeditious Summary Grant Approval Request** The petitioner requests the agency issue a summary grant process for this application. Petitioner has provided in a confidential document attachment labeled as	petitioner	proprietary	information,	specific	exemption	numbers	whereby	the	FAA has already granted a previous exemption similar or identical to each and every request,	herein. For the FAA’s benefit, Petitioner’s Consultant , Gowdy Brothers Aerospace, LLC, has researched, categorized and arranged all 631 exemptions granted as of June 23,
1 The	Company	or	Petitioner	listed	above relies	upon	the	following	exemptions where	specific	reference	to	an	exemption	is	not	provided:	Exemptions	11062	thru 11067,	11080,	11109	through	11112,	11114,	11213,	11062	and	as	recent	as	11857.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 5 2015 into a usable searchable database, based upon the following criteria: date submitted, date grant issued, time to petition grant, petitioner, petitioner’s state, exemption number, sUAV equipment type, grant purpose (mission/operation), along	with	other	supporting data. Petitioner has identified four previous approved exemptions for each of the Petitioners	FAA	submission	requests:

 Commercial	(mission/operation)	purposes;  Type	of	sUAVs	(UAS);  Title	14	Exemptions (exemption	pattern	referenced	in	appendix	A) 2 

### Desc**ription of Type, Make and Models of sUAV/UAS Requested:**  The petitioner is seeking an exemption to commercially operate sUAVs makes and models	as	follows: 1. 3D Robotics Aero – M 101. HexaCrafter HQ
-850 2. 3D Robotics Fixed Wing 102. HexaCrafter HQ
- 1150 3. 3D Robotics Iris 103. HobbyKing Bixler 2 4. 3D Robotics Solo 104. Hoverfly – Livesky 5. 3D Robotics X8 105. HSE UAV – DRASS Q1000 6. 3D Robotics X8+ 106. Hubsan – X4 Microdrone 7. 3D Robotics X8
-M 107. Inova Drone – Inova One 8. 3D Robotics Y6 108. Intuitive Aerial – Aerigon IAH 3 9. AeroCamera
- SR 15 109. Kespry Drone Systems 10. Aerial Pixels
- Fx8Pro Elite 110. KongCopter FQ700 11. Aerialtronics Altura Zenith 111. Latitude Arcturus Jump
- 15 12. AeroCine Kopterworx Hammer X12 112. Latitude Arcturus Jump-20 13. AeroLogix – Geostar 113. Latitude HQ
-20 14. Aeronavics SkyJib
-8 Ti
-QR 114. Latitude HQ
-40 15. Aeronavics X4 Titanium 115. Latitude HQ
-60 16. Aerosky – RoboSurfer 116. Latitude Sensitel Silverfox HQ 17. AeroVironment Puma 117. Leptron – Avenger 18. AeroVironment Qube 118. Lockheed Martin – Desert Hawk III 19. AeroVironment Shrike 119. Lockheed Martin – Indago 20. Aeryon Scout 120. Mavinci – Sirius Pro 21. Aeryon Sky Ranger 121. Microdrones MD4
2 Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b).Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 6 22. AgEagle 122. Microdrones – MD4-200 23. Agribotix Enduro Quad 123. Microdrones – MD4- 1000 24. Agribotix Hornet Drone 124. Microdrones – MD4-3000 25. Aibotix X – 6 125. MikroKopter – ARF OctoXL 26. AirCover ORT
-825 126. MLB
- Super
- Bat UAV 27. AirCover QR
-425 127. Multirotor G4 28. Airfield – Extreme Surfer Power Glider 128. MultiRotor – G4 Blackbird V2 29. AirRobot AR 100
- B 129. MultiRotor – G4 Skycrane 30. AirRobot AR 100
-C 130. Parrot – AR Drone 2 31. AirRobot AR 180 131. ParkZone – Radian RTF 32. AirRobot AR 200 132. Parrot – Bebop 33. Airwing UAV – Talon 133. PrecisionHawk – Lancaster 34. Align M690L Multicopter 134. Precision Drone – PaceSetter 35. Altavian Nova F6500 135. Prioria – Hex 36. Altus UAS Delta X
-4 136. Prioria – Hex Mini 37. Altus UAS Delta X
-8 137. Prioria – Maveric UAS 38. American Drones – Eagle 550 138. ProJet – RC Drone 39. American Drones – Falcon 450 139. ProJet – RQ
- 11 Raven 40. American Drones – Nighthawk 550 140. Pulse Aerospace – Scout B1
-100 41. American Drones – Phoenix 650 141. Pulse Aerospace – Vapor 42. Arch Aerial – Atlas
-1 142. RangeVideo – Jet 43. Arch Aerial – OCTO 143. RF70 Aircraft 44. ARRIS – M680 Hexa 144. RIEGL RiCopter 45. Ascending Technologies – AscTec Falcon 8 145. Ritewing
- Drak 46. Birdseyeview – FireFly 6 146. Ritewing
- Spade 70" 47. Blade 350 QX3 147. Ritewing
- Zephyr 3 Spade 48. Blade Chroma 148. SenseFly eBee 49. Bormatec – Maja UAV 149. SenseFly – eXom 50. Bumblebee Carbon Fiber Quadcopter 150. Sensurion Aerospace – Magpie 51. CarbonCore – Cortex ARTF 151. Skycatch 52. CineStar – 6 MK Heavy Lift RTF 152. Skyhunter 53. Cinestar 8 Octo 153. Skywalker X
-8 54. Cyber Technology – Cyber Quad 154. Splash Drone 55. Delair
-Tech – DT – 18 155. SteadiDrone – Flare 56. DJI
- F450 156. SteadiDrone – Mavrik 57. DJI - F550 157. SteadiDrone – Vader 58. DJI
- Inspire 1 158. Swift Radioplanes – Lynx 59. DJI – Matrice 100 159. T
- Rex 800E Pro 60. DJI
- Phantom 2 160. Tactical Robotics – InstantEye Mk2 61. DJI
- Phantom 3 161. Tarot – 450 62. DJI – Spreading Wings S800 162. Tarot – 690 63. DJI – Spreading Wings S900 163. Tarot – 960 64. DJI – Spreading Wings S1000 164. Tarot
- 680 Pro 65. DJI – Spreading Wings S1000+ 165. Tarot – T18Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 7 66. DraganFlyer
- Commander 166. Tarot – T810 67. DraganFlyer
- Guardian 167. Tayzu Robotics – Quadra 68. DraganFlyer
- X4- ES 168. Tayzu Robotics – Titan X8 69. DraganFlyer
- X4- P 169. TBS Caipirinha V2 70. DraganFlyer – X6 170. Trimble UX5 71. Event 38
- E384 171. Trimble UX5
- HP 72. Finwing – Penguin 1720 172. Trimble ZX5 73. FlyPro PX400 173. Turbo Ace – Cinewing 6 74. FoxTech FPV – D130 X8 V2 174. Turbo Ace – Matrix G 75. FoxTech FPV – K130 V3 175. Turbo Ace – Matrix I 76. Freefly – Alta 176. Turbo Ace – Matrix E 77. GB
-250z 177. Turbo Ace – Matrix S 78. GB
-450z 178. Turnigy Talon Quad 79. Germap – G47
-X8 179. UAV Solutions – Phoenix 30 80. Germap – G65
-Y6 180. UAV Solutions – Phoenix 60 81. Germap – G180 181. UAV Solutions – Phoenix 60LE 82. Germap – G212 182. Vanguard Defense Industries ShadowHawk 83. Germap – SmartOneC 183. Viking UAS – Patriot X4 84. Gryphon Dynamics – Dodeca 184. Viking UAS – Patriot X8 85. Gryphon Dynamics – Hexa 185. Viking UAS – Ranger EX 86. Gryphon Dynamics – Octo 186. Viking UAS – VikingOne 87. Gryphon Dynamics – X8 187. Vi king UAS
- VK X6 Model 800 88. Gryphon Dynamics – Y6 188. Volt Aerial Robotics
- Venture 89. Hawkeye 1700 189. Vulcan – Black Widow 90. Hawk UAS – Silex Systems F15 190. Vulcan – Mantis 91. Helipal
- Storm Drone AntiGravity 191. Vulcan – Raven 92. Helipal
- Storm Drone 4 192. Walkera – QR X350PRO 93. Helipal
- Storm Drone 4 Mini 193. Walkera – QR X800 94. Helipal
- Storm Drone 4 Naza 194. Walkera – QR X900 95. Helipal
- Storm Drone 6 Naza 195. Walkera – Scout X4 96. Helipal
- Storm Drone 8 Naza V2 196. Walkera – Tali H500 97. HexaCrafter HC
-650 197. Walkera – Voyager 3 98. HexaCrafter HC
-800 198. Yamaha RMAX 99. HexaCrafter HC
-1100 199. Yuneec
- Tornado H920 100. HexaCrafter HO
- 1250 200. Yuneec
- Typhoon Q500
Each separately weighs 55 lbs. or less, with imaging payload and applicable equipment. Equipment operation manuals for each sUAV are included for your reference and are considered confidential information for each respective company’s UAS and are affixed	separately	in these	documents labeled Appendix
.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 8 

### Commercial (Mission, Operation) Purpose: This exemption request, once granted would allow the petitioner to operate a small unmanned	aerial	vehicle	(sUAV),	unmanned	aircraft	system	(UAS)	to	conduct	bridge Inspections, flare stack inspection, utility-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction	site inspection	and	monitoring,	public	entity	support	operations,	Aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live f eed and live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production 3, surface mining, closed set filming4, disaster	and	catastrophe	events. 

### Regulations from which the E**xemption Relief is requested**  **:** 14 C.F.R.	§	61.113	(a)	&	(b) 14	C.F.R.	§	61.133(a) 14	C.F.R.	§	91.7(a) 14	C.F.	R.§	91.119 14	C.F.R.	§	91.121 14	C.F.R.	§	91.151	(a) 14	C.F.R.	§	91.405	(a) 14	C.F.R.	§	407	(a)	(1) 14	C.F.R.	§	409	(a)	(2) 14	C.F.R.	§	417	(a)	&	(b) See	Appendix	E

3 Motion	Picture	and	Television	Flight	Operations	Manual	is	herein	attached	as Appendix	G. 4 Motion	Picture	and	Television	Flight	Operations	Manual	for	closed	set	filming	is herein	attached	as	Appendix	G.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 9 

### The name and address of the Petitioner**:** Keystone	Consultants,	Inc. Attn: Matthew	Flaus 32	East	Main	Street Carnegie,	PA	15106 Please	direct	any	question	or	comment	regarding	this	petition	to	Petitioners Consultant:	Gowdy	Brothers	Aerospace,	LLC. 8170	Old	Carriage	Court	N.,	Suite	#200 Shakopee,	MN	55379 www.GowdyBrothersAerospace.com Info@GowdyBrothers.com 

### Background The Petitioner, Keycon Inc is under Matthew Flaus’s direction
. Matthew Flaus is a highly	accomplished,	capable, experienced and trusted	professional. Keystone Consultants, Inc. is a Pittsburgh-based professional and technical firm established in 1991. Keystone provides creative and technical solutions for the complex problems of the energy and telecommunications industries. Privately held, Keystone fosters an entrepreneurial environment and a corporate culture focused on exceeding customer expectations, safety, quality delivery, and employee welfare. Keystone Consultants, Inc., has been providing quality professional surveying services to the energy sector regionally since 1991. Concentrating their efforts on the energy and telecom markets provides their clients a team with a thorough understanding of their customers' expectations and requirements. Their survey crews and scientists are equipped with the latest technology, have OSHA certification, and are experienced in dealing with landowners for infrastructure projects. Mr. Flaus has 19 years of experience in all phases of Surveying. Matt worked for more than 16 years serving the municipal utility and public works market. Currently Matt coordinates Keystones 7-8 survey crews relating to scheduling and QA/QC of the field survey data. Mr. Flaus has a comprehensive understanding of field survey practices, equipment, and the processing of the field information.	Mr.	Flaus	also	has	a	private	pilots	license	and	owns	his	own	aircraft. 

### Commitment to Safety As part of its commitment to safety and innovation, Keycon Inc is asking for this exemption in	part, to reduce the risk of injury to its employees and contractors whoGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 10 participate in the proposed activities the petitioner requests, including but not limited to damage to agriculture, natural habitat, buildings and other structures within	the	United States. 

### Expertise & Experience Keycon Inc and Matthew Flaus, has professional experience as a trusted sUAV pilot and is extremely	qualified and is	considered	an	up	and	coming subject	matter	expert in	their	local area for	UAS	of	all	types,	models	and	makes.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 11 

## The Ex**emp tion Request**  Keycon Inc proposes the use of the sUAVs will be for capture of high resolution imagery and video of residential or commercial applications and purposes to a level of quality that allows the Petitioner to use the imagery to identify, record, memorialize	events	and	objects	according	to	the	purposes	noted. The imagery and video will be used to identify the condition of landscapes, agriculture, events, disasters and infrastructure to conduct bridge inspections, flare stack inspection, utility-power generation system inspections and patrolling, aerial inspection, photography and videography of residential and commercial real estate, weddings, aerial inspection, photography and videography of utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial imaging for safety, monitoring and comparing work efforts and completion percentages, and security of controlled environment of various sites, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs research, risk management and assessment, motion picture production,	surface	mining,	closed	set	filming,	disaster	and	catastrophe	events. The UAS will be operated by a Keycon Inc and or contracting operators on occasion to capture high-resolution imagery/video of large structures (wide and tall) such as warehouses, high rise buildings, bridges, and construction sites, as well as “bird’s eye” views of fire and explosion sites. Given the small size of the sUAVs involved, no more than 5 5 lbs., majority of the speed of operation be between 5 - 1 5 mph and the restricted environment within which they will operate, the Petitioner falls squarely within that zone of safety (an equivalent level of safety) in which Congress envisioned that the FAA must, by exemption, allow commercial operations of UASs to	commence immediately. This exemption application is submitted to fulfill Congress’ express goal in passing Sections 333(a) through (c) of the Reform Act. This law directs the Secretary of Transportation to consider whether certain unmanned aircraft systems may operate safely in the national airspace system (NAS) before completion of the rulemaking required under Section 332 of the Reform Act. In making this determination, the Secretary is required to determine which types of UASs do notGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 12 create	a	hazard to	users	of	the	NAS	or	the	public	or	pose	a	threat	to	national security in	light	of	the	following:

 The	UAS’ size,	weight,	speed,	and	operational	capability;  Operation	of	the	UAS	in	close	proximity	to	airports	and	populated	areas;	and  Operation	of	the	UAS within	visual	line	of	sight	of	the	Operator. Reform Act § 333 (a). Lastly, if the Secretary determines that such vehicles “may operate safely in the national airspace system, the Secretary shall establish requirements	for	the	safe operation	of	such	aircraft	in	the	national	airspace	system.” Id.	§333(c)	(emphasis	added). 5 The Federal Aviation Act expressly grants the FAA the authority to issue exemptions. This statutory authority, by its terms, includes exempting civil aircraft, as the term is defined under §40101 of the Act: The Administrator may grant an exemption from a requirement of a regulation prescribed under subsection (a) or (b) of this section or any of sections 44702 -44716 of this title if the Administrator finds the exemption is in the public interest. 49 U.S.C. §44701(f). See also 49 USC §44711(a); 49 USC §44704; 14 CFR §91.203(a)(1) This authority to grant exemptions	reaches	such	issues	as	authorization	of	commercial operation	of	aircraft without	an	FAA	issued	pilot’s	license. Keycon Inc in filing this application is requesting that the FAA combine the grant of the Section 333 exemption with a standard Certificate of Operation (COA) that will allow commercial operations of its Keycon Inc’s sUAV without the necessity of filing for a COA for each flight, unless such flight is to be conducted in an area not approved in the exemption. Compliance with the conditions agreed to herein and that may be imposed by the FAA, as set forth in prior Section 333 exemptions, provide	the	separation	needed	f rom	other	aircraft. In addition, given that all operations will be conducted below 400 AGL feet and no closer than 5 nautical miles of the geographic center of an airport as denoted on a current FAA published aeronautical chart, unless a letter of agreement with that airport’s management is obtained, Keycon Inc requests that operations over congested or densely populated areas be allowed. The new sUAVs do have GPS geofencing,	it	will	operate	at	a	very	low	altitude,	within confined	areas,	at	low	speed	and weighs no more than 55 lbs. Such operations will only be under-taken with the approval of the land or home owner, as set forth herein, and will comply with the requirements that operations be no closer than 500 feet to the adjacent building

5 Applicant	interprets	this	provision	to	place	a	duty	on	the	Administrator	to	not	only process applications for exemptions under section 333, but for the Administrator to craft conditions	for	the safe	operation	of	the	UAS,	if	it	should	be	determined	that	the conditions	set	forth	herein	do	not	fulfill	the	statutory	requirements	for	approval.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 13 unless the	land owner has	provided	permission,	and	the	Operator	has	made	a	safety assessment	of the	risk	from	such	operations. 

### Operator Requirements Given	the	sUAV proposed	by Keycon	Inc, Operators	should	not	be required to hold	a private pilot license. Keycon Inc believes that 1) the operator, instead of understanding	how to	operate	a	passenger	carrying	aircraft,	should	have	knowledge and experience that enables the safe operation of a small, remotely piloted sUAV should understand airspace restrictions and know how to ensure separation from other aircraft as well as non-participants and property; 2) the sUAV has built-in technical capabilities that limit the potential for unsafe operation and 3) there are other security screening mechanisms already in existence that Keycon Inc will utilize to ensure the operators are acting consistently with national security interests. Given the sUAV safety features outlined below, Keycon Inc proposes that its operations under this Exemption request should not be required to hold a commercial or private pilot certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents; have completed Keycon Inc’s training program for operation of the UAS. Keycon Inc notes that 1) the FAA has found that safety factors permitted operation of sUAVs by Operators with these qualifications in the case of operations pursuant to public COAs when the mandatory operating conditions specified above were present; and 2) that the Notice of Proposed Rulemaking entitled Operation and Certification	of	Small	Unmanned	Aircraft Systems,	80	F.R.	9544	(February 23, 2015) (“NPRM”), does not require the operator to hold a private pilot license or a third class	medical. Advanced sUAVs have a navigation and control system and auto -pilot that allows it to execute very accurate pre-programed flights. Flights are pre-programmed with GPS waypoint to establish perimeters beyond which the aircraft will not operate. Flights under auto-pilot are not directed by positive manual input, but through preprogrammed flight parameters that are executed by the auto -pilot. In the case of unplanned	events,	the	Operator	inputs	preprogrammed evasive	maneuvers	from	the control unit, and the autopilot executes those maneuvers. Pre-programmed Operator interventions include : initiation of holding at present position; suspension of mission; fly back to launch point; abort mission and land immediately; and emergency power cut off and land (flight termination system). Additional automated safety functions and safety enhancing features of the advanced sUAVs may include	the	following:Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 14 1) Auto -pilot detection of lost GPS or of insufficient satellites initiates an immediate landing, 2) Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels. Low	power	below 10%	triggers	an	immediate	landing, 3) If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position at its current location for 5 seconds and if the signal is not restored, execute	a	return to	home	and	land, 4) Redundant “kill switches” that enable completely shutting the aircraft down in	flight	in the	event	of	a	loss	of	control	or	un
-commanded deviation	from	the flight	path, 5) The	aircraft,	weighs less	than 55 lbs.,	fully	loaded, 6) The	motors	are	driven	by	pulse	width	modulated	signals,	not	analog	signals, 7) The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude) or a maximum	of	400	feet AGL. See Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20 - 21 (July 30, 2013); As the FAA has determined in	Exemptions	11062	thru	11067,11080	and	11110	(the “Exemptions”), in comparing the requirements for private pilot knowledge and the knowledge required for a commercial pilot, that knowledge associated with a private pilot license, and therefore private pilot ground school, was sufficient to allow private pilots	to	operate	sUAVs under	those	exemptions. Based upon that analysis, Keycon Inc believes successful completion of FAA private pilot ground school is a suitable predicate to operating the sUAV under this exemption. Keycon Inc proposes that the Operator accumulate required sUAV flight training hours through the operation of sUAVs rather than flight hours in conventional aircraft. Those hours are more relevant to the operations proposed herein than hours gained in obtaining a private pilot’s certificate in conventional or rotor aircraft. Those aircraft are orders of magnitude heavier than the sUAS and carry not only the pilot himself, but also passengers and fuel, none of which is carried in	the	sUAS.	These	conventional	aircraft	fly	over	all	sorts	of	airspace	without the	permission	or	knowledge	of	the landowner
. A	handheld	radio	controller	controls	the	sUAV and	the	vehicle	is	operated	within	the line of sight. The requirements of Part 61.127 (commercial flight proficiency) and §61.107 (private flight proficiency), to the extent they are relevant to UAS operations, can be taught in the training proposed herein. As a review of the requirements of part 61.127 and 107 demonstrate, the issues presented as they relate to a 55 -pound aircraft, operating at less than 30 mph during filming operations are those taught in ground school and in flight training with the particular UAS and not gained from accumulating flight hours in a fixed wing or rotorcraft gas or jet A powered aircraft completing cross country flights and take offs	and	landings	at	controlled	and	uncontrolled	airports.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 15 As to national security review of pilots, each of Keycon Inc’s pilots/operators will obtain	internally provided certified	training (Ground and Practical)	from Keycon	Inc to operate the sUAV. This review and certification could reasonably vet the Operators against any known terrorist or no fly listings that are relevant and publically	available. Keycon Inc additionally asks that the exemption be issued without the requirement for a visual observer. As set forth herein, an equivalent level of safety is provided by the size, speed and control capabilities of the aircraft, as well as the operational procedures that	will	be applicable	to	all	flight	hereunder.	These	obviate	the	need	for the	visual	observer. The	Operator will	be	operating	the	aircraft,	always	within	line	of	sight.	He	or	she	will walk and follow the aircraft around the inspection area so that while it is flying its pre-programed and at times, manual flight path, the UAS will always be directly in his or her line of sight. The Operator will not be distracted by viewing the pictures taken during the flight. Rather, once the sUAV is launched, the Operator’s only duty will be to watch the flight of the UAS over the structure and intervene to address flight path deviations or other issues that arise during the flight. The functions that an observer performs where the aircraft is flown at long distances from the launch area will not be necessary as the Operator will always have the aircraft in his or her direct sight. The observer also will not be necessary because the Operator will conduct a pre-flight inspection of the area, will and if needed, cordon off the area and	will	perform	frequent	visual	scans	of	the	area	while	the	vehicle	is	operating. Keycon Inc again notes that the NPRM does not require the use of a visual observer. Given the clear direction in Section 333 of the Reform Act; the authority contained in the Federal Aviation Act, as amended; the strong equivalent level of safety surrounding the proposed operations, and the significant public benefit, including enhanced safety, reduction in environmental impacts, including reduced emissions associated with allowing battery powered sUAVs for these functions instead of turbine or gas power aircraft/rotorcraft and operations with pilots having at least a private	pilot	license,	the	grant	of	the	requested	exemptions	is	in	the public	interest. 6

6 Should the FAA determine that it cannot grant such an exemption for operations without a FAA licensed private pilot, despite the showing made herein, under the statutory authority the FAA already has, the	Company	or	Petitioner	listed	above will operate its aircraft with pilots holding at least a private pilot certificate issued by the FAA. In that event, the Company or Petitioner requests that the exemption be granted with conditions similar to those contained in numbered paragraphs 14- 15 in	Exemption	11136Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 16 

### Aircraft and Equivalent Level of Safety The Petitioner proposes that the exemption requested herein apply to civil aircraft that have the characteristics and that operate with the limitations listed herein. These limitations provide for at least an equivalent or even higher level of safety to operations under the current regulatory structure because the proposed operations represent a safety enhancement to the operations conducted with conventional aircraft or with humans climbing up and around structures. These conditions are drawn from Exemptions 11136, 11138, 11172, 11174 and 11177, 11062, 11109, 11112,	and	11213 and as	recent	as	11857. These limitations and conditions to which Keycon Inc (referred to as “Operator”) agrees to be bound when conducting commercial operations under an FAA issued exemption include:

1) Operations authorized by this grant of exemption are limited to the	aircraft described in	the	Operator’s manual,	which	is	a	multirotor weighing up to 5 5 pounds. Proposed operations of any other aircraft will require a new petition or a petition to amend this	grant. 2) The UA may not be flown at an indicated airspeed exceeding 30 mph (10 mph during	inspections). 3) The UA must be operated at an altitude of no	more than 400 feet above ground level (AGL), as indicated by the procedures specified in the Operator’s manual. All altitudes reported to ATC must	be	in	feet	AGL. 4) The	UA	must	be	operated	within	visual	line	of	sight	(VLOS)	of	the Aircraft Operator	at	all	times.	This	requires	the	Aircraft Operator to be able to use human vision unaided by any device other than corrective	lenses. 5) The	Exemption	Holder’s	Manuals	must	be	amended	to	include	all conditions and limitations required by the FAA. The Manuals must be maintained and made available to the Administrator upon	request.	If	a	discrepancy	exists	between	the conditions	and limitations in the exemption and the procedures outlined in the Exemption Holder’s Operator’s manual, the conditions and limitations in the exemption take precedence and must be followed. Otherwise, the Aircraft Operator must follow the procedures as outlined in its Aircraft’s manual. The Exemption Holder may update or revise its Manuals. It is the Exemption Holder’s responsibility to track such revisions and present updated and revised documents to the Administrator uponGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 17

request. The Exemption Holder must also present updated and revised documents if it petitions for an extension or amendment of this exemption. If the Exemption Holder determines that any update or revision would affect the basis upon which the FAA granted this exemption, then the Exemption Holder must petition	for	amendment	to	its exemption. 6) Prior	to	each	flight,	the	Aircraft	Operator	must	inspect	the UAS	to ensure it is in a condition for safe flight. If the inspection reveals a	condition	that	affects	the	safe operation	of	the	UAS,	the	aircraft is prohibited from operating until the necessary maintenance has	been	performed,	and	the	UAS	is	found	to	be	in	a	condition	for safe flight. The Ground Control Station must be included in the preflight inspection. All maintenance and alterations must be properly	documented	in	the aircraft	records. 7) Any UAS that has undergone maintenance or alterations that affect the UAS operation or flight characteristics, e.g., replacement of a flight critical component, must undergo a functional test flight in accordance with the Exemption Holder’s Manuals. The Aircraft Operator who conducts the functional test flight must make an entry in the UAS aircraft records of the flight. The requirements and procedures for a functional test flight and aircraft record entry must be added to the Exemption Holder’s	Operator’s	manual. 8) The Exemption Holder must follow the manufacturer’s UAS aircraft/component, maintenance, overhaul, replacement, inspection, and life limit requirements, with particular attention to flight critical components that may not be addressed in the manufacturer’s	manuals. 9) The Exemption Holder must carry out its maintenance, inspections, and record keeping requirements in accordance with the Operator’s Manuals. Maintenance, inspection, and alterations must be noted in the aircraft logbook, including total flight	hours,	description	of	work	accomplished,	and	the	signature of the authorized	technician	returning	the	UAS	to	service. 10) The authorized technicians must receive and document training referenced	in	the Exemption	Holder’s	Manuals. 11) Each UAS operated under this exemption must comply with all manufacturer System	and	Safety Bulletins. 12) The Exemption Holder’s maintenance personnel must make a record entry in the UAS logbook or equivalent document of theGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 18

corrective action taken against discrepancies discovered between	inspections. 13) Prior	to	commencing	operations,	the	Aircraft	Operator	shall	have logged at least 25 hours of total time as a UA rotorcraft pilot and at	least	ten	hours	logged	as	a UA pilot	with	a	similar	UA	type	and 5	hours	in	the	make	and	model. 14) If the UAS loses communications or loses its GPS signal, the UA must return to a pre-determined location within the private or controlled-access property and land or be recovered in accordance	with	the	Exemption	Holder’s	Manuals. 15) The Aircraft Operator must abort the flight in the event of unpredicted obstacles or emergencies, including unauthorized people entering the flight area, in accordance with the Exemption	Holder’s	Manuals. 16) The Aircraft Operator is prohibited from beginning a UAS flight unless (considering wind	and	forecast	weather conditions)	there is enough power to fly to the first point of intended landing and, assuming normal cruising speed, to fly after that for at least 10 minutes. 17) All aircraft operated in accordance with the exemption must be identified by serial number, registered in accordance with 14 CFR part 47, and have identification (N
- Number) markings in accordance with 14 CFR part 45, Subpart C. Markings must be as large	as	practicable. 18) Before conducting operations, the radio frequency spectrum used for operation and control of the UA must comply with the Federal Communications Commission (FCC) or other appropriate	government oversight	agency	requirements. 19) The documents required under 14 CFR 91.9 and 91.203 must be available to the Operator at the Ground Control Station of the UAS	any	time	the	aircraft	is operating.	These	documents	must	be made available to the Administrator or any law enforcement official	upon	request. 20) The UA must remain clear and yield the right of way to all other manned operations and activities at all times (including, but not limited to, ultra-light vehicles, parachute activities, parasailing activities,	hang	gliders,	etc.).Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 19

21) The UA may not be operated by the Aircraft Operator from any moving	device	or vehicle. 22) UAS	operations	may	not	be	conducted	during	night,	as	defined	in 14	CFR	1.1. 23) All operations must be conducted under visual meteorological conditions (VMC). The UA may not be operated less than 500 feet below or less than 2,000 feet horizontally from a cloud or when	visibility	is	less	than	3	statute	miles	from	the Operator. 24) During operations the UA may not operate within 5 nautical miles of the geographic center of an airport as denoted on a current FAA-published aeronautical chart unless a letter of agreement with that airport’s management is obtained, and the operation is conducted in accordance with a NOTAM, if as required	by	the	Operator’s	COA.	The	letter	of	agreement	with	the airport management must be made available to the Administrator	upon	request. 25) The UA may not be operated over congested or densely populated	areas	unless the conditions	set	for	in	#26	are	satisfied. These populated areas include but are not limited to the yellow areas depicted on World Aeronautical Charts (WAC), Sectional Aeronautical Charts (Sectionals), or Terminal Area Charts (TAC). However, aeronautical charts may not reflect pertinent local information. Ultimately, it is the Operator’s responsibility to maintain the minimum safe altitudes required by § 91.119 (d) (1). 26) Flight operations must be conducted at least 500 feet from all nonparticipating persons, vessels, vehicles, and structures unless: a. Barriers or structures are present that sufficiently protect nonparticipating persons from debris in the event of an accident. The Aircraft Operator must ensure that nonparticipating	persons	remain under	such	protection.	If	a situation arises where nonparticipating persons leave such protection and are within 30 feet of the UA, flight operations	must	cease	immediately	and/or; b. The aircraft is operated near vessels, vehicles or structures where the land owner/controller has granted permission and/or the Aircraft Operator has made a safety assessment of	the	risk	of operating	closer	to	those	objects	and;Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 20

c. Operations near the Aircraft Operator do not present an undue	hazard to	the	Operator	per	§	91.119(a). 27) All operations shall be conducted over private or controlledaccess	property with	permission	from	the	land	owner/controller or authorized representative. Permission from land owner/controller or authorized representative will be obtained for	each	flight	to	be	conducted. 28) Any incident, accident, or flight operation that transgresses the lateral or vertical boundaries of the operational area as defined by the applicable COA must be reported to the FAA’s UAS Integration Office (AFS
-80) within 24 hours. Accidents must be reported to the National Transportation Safety Board (NTSB) per	instructions	contained	on	the	NTSB	Web	site: www.ntsb.gov
. 

### Specific Uses Public Benefits Keycon Inc proposes use of its sUAV provided equivalent or augmented levels of safety	for	each	of	the	uses	proposed	herein: The present systems of photography and videography and mapping of inspecting the roofs, agriculture land, buildings and large structures site surveys, wild life monitoring, mosquito and insect control are now conducted by either a person wading through swamps, climbing on the roofs and structures that are steep, tall, slippery,	weakened	or	otherwise	hazardous	or	by	the	use	of conventional	aircraft. The current procedures can result in significant injuries to the people who must climb	on	the	roofs	or	require	the	use	of	aircraft	that	are	orders	of	magnitude	greater in size than the sUAV. Either method, manual inspection or large conventional aircraft, results in increased risk of injury due to personnel falling off roofs or ladders, carrying heavy ladders and dealing with confined and dangerous spaces, or increased risk from low altitude flyovers with helicopters or fixed wing aircraft inspecting buildings after damage from storms or other disasters, such as earthquakes or fires. Such flights are, of course, significantly more expensive than those	undertaken	with	a	sUAV
. The present system exposes those not only in the immediate area of inspection, but those who are along the path of flight associated with the arrival and departure of the conventional aircraft at the inspection site	because the aircraft must be flown to and from the site. By contrast, the sUAV is carried to the site and transits no other property. Conventional aircraft carry flammable fuels that are not carried by the UAS and emit pollutants associated with internal combustion engines. The sUAVs proposed	herein	are battery	powered	and	have	no	emissions.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 21 

### Equivalent Level of Safety **14	C.F.R.	§	61.113(a)	&	(b);:	Private	Pilo t	Privileges	and**  **Limitations;	Pilot	in Command;**  Section 61.113(a) & (b) limit private pilots to non-commercial operations. Unlike a conventional aircraft that carries a pilot, passengers, and cargo, the Keycon Inc’s sUAV is remotely controlled with no passengers or property of others on board. Section	61.133(a)	requires	an	individual	with	a commercial	pilot’s	license	to	be	pilot in	command	of	an	aircraft	for	compensation	or	hire. Keycon Inc respectfully proposes that Operator requirements should take into account the characteristics of the particular UAS. Keycon Inc’s sUAV has a high degree of pre-programmed control and various built-in technical capabilities that strictly limit	the	potential for operation outside	of	the	operating	conditions	set	forth in the exemption application. The Keycon Inc’s sUAV has navigation and control system comprised of a Ground Control Station (GCS) and auto-pilot system that can be pre-programmed to set operational boundaries
. All flights are pre-programmed with precision GPS guidance
. In the case of unplanned events, the Operator may input pre-programmed evasive maneuvers from the control unit, and the onboard autopilot executes those maneuvers. Pre-programmed Operator interventions include initiation of holding at present position; suspension of mission; fly back to launch	point;	abort	mission	and	land	immediately;	and emergency	power	cut	off	and land	(Flight	Termination	System). Additional automated safety functions and safety enhancing features of the Keycon Inc’s sUAVs may include	the following: 1.1. Auto-pilot detection of lost GPS or of insuf ficient satellites initiates an immediate landing. 1.2. Low power on the aircraft triggers escalating alarms at GCS at 35% and 10% levels.	Low	power below 10%	triggers	an	immediate	landing. 1.3. If the auto-pilot detects a lost-link to the ground controller, the UAS will hold position	at	its	current	location	for	5	seconds	and	if	the	signal is	not restored, execute	a	return	to	home	and	land. 1.4. Redundant “kill switches” that enable completely shutting the aircraft down in flight in the event of a loss of control or un-commanded deviation	from	the	flight	path. 1.5.	The	aircraft,	weighs	less than 5 5 lbs.,	fully	loaded. 1.6. The motors are driven by pulse width modulated signals, not analog signals. 1.7. The aircraft will operate for the Purposes at no more than 30 mph (while imaging) nor above 200 feet above the structure (imaging altitude)	or	a	maximum	of	400 AGL.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 22 Given these safety features, Keycon Inc proposes that Operators of the Keycon Inc’s sUAV should not	be	required	to	hold	a	commercial	or	private	pilot	certification. Instead, Operators should be required to: have successfully completed, at a minimum, FAA private pilot ground instruction and passed the FAA Private Pilot written examination or FAA-recognized equivalents; have completed the manufacturer’s	or Keycon	Inc’s training	program	for	operation	of the	UAS. Keycon Inc notes that the FAA has found that safety factors permitted operation of UASs by Operators with these qualifications in the case of operations pursuant to public COAs where the mandatory operating conditions specified above were present. See, Federal Aviation Administration, Notice N-8900.227, Unmanned Aircraft Systems (UAS) Operational Approval, at 20 - 21 (July 30, 2013). Likewise, Keycon Inc notes that the NPRM does not require that the Operator hold a private pilot	license	issued	by	the	FAA. Given these conditions and restrictions, an equivalent level of safety will be provided by allowing operation of the Keycon Inc’s sUAV without a private pilot’s certificate	or	a	commercial	pilot’s certificate,	under	the	conditions	set	forth	herein. The risks associated with the operation of the Keycon Inc’s sUAV (given its size, speed,	operational capabilities, and lack of combustible	fuel)	are	so	diminished	from the level of risk associated with private pilot operations or commercial operations contemplated by Part 6 1 with conventional aircraft (fixed wing or rotorcraft), that allowing operations	of	the	UAS	as	set	forth above meets	or	exceeds	the	present	level of safety provided under 14 C.F.R. § 61.113(a) & (b) and does not rise to the level of requiring	a	commercial pilot	to	operate	the	aircraft	under §	61.133(a). 

### 14 C.F.R. § 91.7(a): Civil aircraft airworthiness. This regulation requires that no person may operate a civil aircraft unless it is in airworthy condition. Should the exemption be granted allowing commercial operation of the UAS without an airworthiness certificate, no standard will exist for airworthiness of the UA. Given the size of the aircraft and the requirements that the Operator has agreed to as it relates to airworthiness, as contained in the manual, an equivalent level of safety will be achieved by insuring compliance with the manuals prior to each flight. The FAA has granted exemptions to conduct similar operations in	Exemptions	11062	through	11067,	11080	and	11110. 

### 14 C.F.R. §91.119: Minimum **safe altitudes**Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 23 Section 91.119 establishes safe altitudes for operation of civil aircraft. Section 91.119 (d) allows helicopters to be operated at less than the minimums prescribed, provided the person operating the helicopter complies with any route or altitudes prescribed for helicopters by the FAA. As this exemption is for a sUAS that is a helicopter and the exemption requests authority to operate at altitudes up to 400 AGL,	an	exemption	may	be	needed	to	allow	such	operations. The equivalent level of safety will be achieved given the size, weight, and speed of the UAS as well as the location where it is operated. No flight will be taken without the permission of the property owner, facility owner, and/or local officials. Because of	the	advance	notice	to the property	owner	and	participants,	all	affected	individuals will be	aware	of	the	planned	flight operations	as	set	forth	in	the	Manuals.	Compared to flight operations with aircraft or rotorcraft weighing far more than the maximum 55 lbs. and the lack of flammable fuel, any risk associated with these operations is far less than those presently presented by conventional aircraft operating at or below 500 AGL in the aerial photography industry. In addition, the low-altitude operations of the sUAS will ensure separation between these small-UAS operations and the operations of conventional aircraft that must comply with Section 91.119. The FAA has granted exemptions to conduct similar operations in Exemptions 11062	through	11067,	11080	and 11110. 

### 14 C.F.R. §91**.121 Altimeter Settings** This regulation requires each person operating an aircraft to maintain cruising altitude by reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” As the Keycon Inc’s sUAV, in manual or emergency mode, will not have a barometric altimeter display, but instead a GPS altitude display, an exemption will be needed. The Operator, pursuant to the procedures set forth in the Manuals as indicated before flight, will achieve an equivalent level of safety
. The FAA has granted exemptions to conduct similar operations in Exemptions 11062 through 11067, 11080 and	11110. 

### 14 C.F.R. § 91.151(a): Fuel Requirements for Fl **ight in VFR Conditions** Section 91.151(a) prohibits an individual from beginning “a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing, and, assuming normal cruising speed

– (1) During the day, to fly after that for at least 30 minutes; or	(2)	At	night,	to	fly	after	that	for	at	least	45 minutes.” The battery powering the sUAS provides approximately 40 minutes of powered flight. To meet the 30 -minute reserve requirement in 14 CFR §91.151, sUAS flightsGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 24 would	be	limited	to approximately	10	minutes	in	length.	Given	the	limitations	on	the UAS’ proposed flight area and the location of its proposed operations within a predetermined	area,	a	longer	time	frame	for flight	is	reasonable. Petitioner believes that	an	exemption	from	14 CFR	§91.151(a)	falls	within	the	scope of prior exemptions. See Exemption 10673 (allowing Lockheed Martin Corporation to operate without compliance with FAR 91.151 (a)). Operating the small UAS, in a tightly controlled area where only people and property owners or official representatives	who	have	signed waivers will be	allowed,	with	less	than	30 minutes of reserve fuel, does not engender the type of risks that Section 91.151 (a) was intended	to	alleviate	given	the	size	and	speed	of	the	small	UAS. Petitioner believes that an equivalent level of saf ety can be achieved by limiting flights to 30 minutes or 25% of remaining battery power whichever happens first. This restriction would be more than adequate to return the sUAS to its planned landing zone from anywhere in its limited operating area. Similar exemptions have been	granted	to	other	operations,	including	Exemptions	2689F, 5745, 10673, 10808 and	Exemptions	11062,	through110 67,	11080	and	11110. 

### 14 C.F.R. §91.405 (a); 91.407 (a) (1); 91.409(a) (2); 91.417(a) & (b): Maintenance **Inspections** These regulations require that an aircraft Operator or owner “shall have that aircraft inspected	as	prescribed	in	subpart	E	of	this	part and	shall	between	required inspections, except as provided in paragraph (c) of this section, have discrepancies repaired as prescribed in part 43 of this chapter...,” and others shall inspect or maintain	the	aircraft	in	compliance	with	Part	43. Given that these sections and Part 43 apply only to aircraft with an airworthiness certificate, these sections will not apply to the Petitioner. Maintenance will be accomplished by the Operator or manufacturer pursuant to the flight manual and operating handbook as referenced in the Manuals attached as confidential Exhibits an equivalent level of safety will be achieved because these small UASs are very limited in size and will carry a small payload and operate only in defined areas for limited	periods	of	time.	If	mechanical	issues	arise,	the	UAS can	land	immediately	and will be operating from no higher than 400 feet AGL. As provided in the Aircraft Flight Operations Manual the Operator will ensure that the UAS is in working order prior to initiating flight, perform required maintenance, and keep a log of any maintenance performed. Moreover, the Operator and manufacturer are most familiar with the aircraft and best suited to maintain the aircraft in an airworthy condition to provide the equivalent level of safety. The FAA has granted exemptions for	similar	operations	in	Exemptions	11062	through 11067,	11080	and	11110.

*********Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 25 

## Fe**der al R** **egister Publication** Pursuant to 14 C.F.R. Part 11, the following summary is provided for publication in the Federal	Register, should	it	be	determined	that	publication	is	needed: Petitioner seeks	an	exemption	from	the	following	rules: 14	C.F.R.	§§	61.113(a)	&	(b);	91.7(a);	91.119;	91.121;	91.151(a);	91.405(a); 91.407(a)(1); 91.409(a)(2) and 91.417 (a) & (b) to operate commercially a small unmanned vehicle (55 lbs. or less) for the following purposes: to conduct bridge inspections, flare stack inspection, utility-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority officials, aerial video and photography for public and private use including television, public events, and cinematography live feed and live	newsgathering,	training	to	persons	individually	or	belonging	to	both	private	and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools, colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster	and	catastrophe	events. 

## Priv**acy and National Security** All	flights	will	occur	over	private	or	controlled	access	property	with	the	property owner’s prior	consent	and	knowledge.	Inspection	will	be	of	inanimate objects	in areas	where	the	owners will	have	consented	to	the	inspections	or	otherwise	have agreed	to	allow	the	UAS	and	the Operator	to	be	in	the	area	where operations will take	place. The	size	of	the	UAS,	its	speed	and	restricted	area	of	operation	do not	raise	national security	issues. 

## SummaryGowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 26 Approval of exemptions allowing commercial operations of sUAVs for petitioner to operate an unmanned aircraft system (UAS) to conduct bridge Inspections, flare stack inspection, utility-power generation system inspections and patrolling, aerial inspection and photography of residential and commercial utility infrastructure including but not limited to electrical power lines, wind turbines and cell towers, pipeline inspection and patrolling, filmmaking, cinematography, and videography, precision agriculture with on board sensors, wildlife and forestry monitoring and mosquito and insect control, aerial surveying, construction site inspection and monitoring, public entity support operations, aerial video and live video feed to assist with search and rescue operations under the authority and support of local authority	officials,	aerial	video	and	photography	for	public	and	private	use	including television, public events, and cinematography live feed and live newsgathering, training to persons individually or belonging to both private and public organizations to increase awareness and improve safety for current and future UAS operations within the NAS, special events: including high schools. colleges, professional sports, open air events and fairs, research, risk management and assessment, motion picture production, surface mining, closed set filming, disaster and	catastrophe	events, will	enhance safety	by	reducing	risk. Conventional operations, using jet or piston powered aircraft, ladders or placing people in	swamps, on	roofs	or	tall,	hazardous	or	weakened	structures,	exposes	them to higher risks than those created by use of a sUAVs. Conventional aircraft that operate at extremely low altitudes just feet from the subject being inspected and in extreme proximity to people and structures present the risks associated with vehicles that weigh in excess of 6,000 lbs., carrying large amounts of jet A or other fuel (140 gallons for jet helicopters). Such aircraft must fly to and from the project location. In contrast, a sUAV weighing fewer than 55 lbs. and powered by batteries eliminates virtually all of that risk given the reduced mass and lack of combustible fuel carried on board. The sUAV is carried to the target area and not flown. The sUAV will carry no passengers or crew and, therefore, will not expose them to the risks	associated	with	manned aircraft	flights. The operation of small UASs, weighing less than 5 5 lbs., conducted under the strict conditions outlined above, will provide an equivalent level of safety supporting the grant	of	the exemptions	requested	herein.	These	lightweight	aircraft	operate	at	slow speeds, close to the ground, and in areas that are under the control of the customer for the operations and, as a result, are far safer than conventional operations conducted with turbine helicopters operating in close proximity to the ground and people	or	the	use	of	individuals	to	climb	the	structures	to conduct	the operations. Satisfaction of the criteria provided in Section 333 of the Reform Act of 2012
–size, weight, speed, operating capabilities, proximity to airports and populated areas and operation within visual line of sight and national security
– provide more than adequate justification for the grant of the requested exemptions allowing commercial operation of Petitioner’s UAS for the Purposes outlined herein and are consistent with exemptions already granted, including Exemptions number 11 171Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 27 through 11174, 11176, 11177, 11062, 11109, 11112, and 11213 and as recent as 11857.

Sincerely, Matthew	Flaus Keystone	Consultants,	Inc. 32	East	Main	Street Carnegie,	PA	15106 and Stephen	Gowdy Chief	Pilot, Gowdy	Brothers	Aerospace,	LLC Consulting	Agent	for Keystone	Consultants,	Inc.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 28 

### APPENDIX A **- EXEMPTION PATTERN**  Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 29 

### APPENDIX B **- TECHNICAL MANUALS AN** **D SPECIFICATIONS** Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform Act Section 333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 30 

### APPENDIX C **- COMMERCIAL (MISSION/OPERATION) PURPOSE**  **- FAA**  **PREVIOUS AP PROVED EXEMPTION NUMBER** **S** Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 31 

### APPENDIX D **- EQUIPMENT**  **- FAA PREVIOUS APPROVED EXEMPTION**  **NUMBER S**  Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 32 

### APPENDIX E **- EXEMPTION**  **14 C.F.R -**  **FAA PREVIOUS APPROVED**  **EXEMPTION NUMBER S**  Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §55 2 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 33 

### APPENDIX F **- MONTHLY MAINTENANCE**  **AND REPAIR LOG**
Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.Gowdy	Brothers	Aerospace,	LLC 8170	Old	Carriage	Court	N.,	Suite	#200,	Shakopee,	MN	55379 www.GowdyBrothersAerospace.com 763 -496-9551 Page 34 

### APPENDIX G **– MOTION PICTURE AND TELEVISION FLIGHT OPERATIONS**  **MANUAL VERSION 1.0** Petitioner submits the Appendix and Manuals marked “CONFIDENTIAL,” as they contain proprietary confidential business information that is not released to the public and is protected under the Freedom of Information Act 5 USC §552 et. seq. 5 Reform	Act	Section	333	(b). Submitted	under	separate	cover.